IRS Provides Transition Relief For 2014 Information Reporting Requirements And Employer Shared Responsibility Provisions

In Notice 2013-45, the Internal Revenue Service has provided transition relief for 2014 from: (1) the information reporting requirements applicable to insurers, self-insuring employers, and certain other providers of minimum essential coverage under Code Sec. 6055; (2) the information reporting requirements applicable to large employers under Code Sec. 6056; and (3) the employer shared responsibility provisions under Code Sec. 4980H. The transition relief is provided to allow additional time for input from employers and other reporting entities in an effort to simplify information reporting consistent with effective implementation of the law.

This transition relief also is intended to provide employers, insurers, and other providers of minimum essential coverage time to adapt their health care coverage and reporting systems. The information reporting and the employer shared responsibility provisions will both be fully effective for 2015. In preparation for that, employers and other reporting entities are encouraged to voluntarily comply with the information reporting provisions for 2014.

The transition relief, which is provided in a question-and-answer format, addresses: (1) when rules will be published regarding Code Sec. 6055 and Code Sec. 6056 information reporting; as well as how these provisions will apply to 2014; (2) what the 2014 transition relief for Code Sec. 6056 information reporting means for application of the employer shared responsibility provisions for 2014; and (3) whether there is an effect on employees’ access to the health insurance premium tax credit.

This transition relief will have no effect on the effective date or application of other Patient Protection and Affordable Care Act provisions, such as the health insurance premium tax credit under Code Sec. 36B and the individual shared responsibility provisions under Code Sec. 5000A.

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